Wilkinson v. Commissioner
United States Tax Court
Petitioner claimed various deductions, but consistently refused to substantiate them, relying on various frivolous alleged constitutional defenses which, as petitioner was informed, have been repeatedly rejected by this Court. Held, respondent's disallowance of the deductions for lack of substantiation is upheld.
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Petitioner claimed various deductions, but consistently refused to substantiate them, relying on various frivolous alleged constitutional defenses which, as petitioner was informed, have been repeatedly rejected by this Court. Held, respondent's disallowance of the deductions for lack of substantiation is upheld. Held, further, on respondent's motion, damages of $ 500 under sec. 6673, I.R.C. 1954, are awarded against petitioner for instituting these proceedings merely for delay.
1Opinion of the Court
Hall, Judge:
Respondent determined a deficiency of $729 in petitioners’ income tax for 1973. The issues for decision are:(1) Whether petitioners are entitled to certain itemized deductions claimed on their 1973 tax return; and(2) Whether petitioners are liable for damages under section 66731 for instituting proceedings before this Court merely for delay.
FINDINGS OF FACT
Some of the facts have been stipulated by the parties and are found accordingly.
At the time they filed their petition, petitioners were residents of Boise, Idaho.
Petitioners timely filed their joint income tax return for 1973.…
2Cases cited22 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Helvering v. TaylorSupreme Court of the United States · 1935
- Rogers v. United StatesSupreme Court of the United States · 1951
- Brown v. WalkerSupreme Court of the United States · 1896
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3Cited by271 opinions
- Jarvis v. CommissionerUnited States Tax Court · 1982
- Abrams v. CommissionerUnited States Tax Court · 1984
- Pierson v. CommissionerUnited States Tax Court · 2000
- White v. CommissionerUnited States Tax Court · 1979
- Greenberg v. CommissionerUnited States Tax Court · 1980
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